Terms and Conditions

By accessing the WITHBIT Platform or using the Services (including by clicking "I AGREE"), you agree to be legally bound by these Terms and all terms incorporated by reference.

1. SUMMARY OF KEY TERMS

1-1. The WITHBIT Platform is an online Digital Assets trading platform and exchange provided by and proprietary to INBLOCK Ltd.

1-2. By visiting, accessing or using the WITHBIT, you confirm, represent and warrant that:

1-2-1. you (as the User) are at least 18 years old;

1-2-2. you have the legal capacity to accept these Terms and to agree to be bound by the Terms in their entirety;

1-2-3. you have provided WITHBIT accurate, true and complete information about yourself as a "User";

1-2-4. that all funds exchanged or to be exchanged by you in the future using the WITHBIT Platform are not and will not be the direct or indirect proceeds of any criminal or fraudulent activity;

1-2-5. you are not located in, or resident of, any jurisdiction where the provision or use of the WITHBIT Platform would be contrary to applicable laws, rules or regulations of any Regulatory Body or where WITHBIT is not authorized to provide such a platform and/or the Services;

1-2-6. you have not previously been suspended or removed from the WITHBIT Platform; and

1-2-7. you have read, understood and agree to our AML Policy, Privacy Policy, Fee Schedule and Transfer Costs Schedule (all of which are expressly incorporated into these Terms).

1-3. Trading Digital Assets carries a high level of risk, and may not be suitable for you. You should be aware that you may sustain a total loss of the funds in your User Account. When accessing or using the WITHBIT Platform, please consider the trading risks detailed in section 4 below. You acknowledge that you are solely responsible for determining the nature, potential value, suitability, and appropriateness of these trading risks for you, and that WITHBIT (and the INBLOCK Ltd.) does not give advice (legal, tax, investment or other) or recommendations regarding Digital Assets including the suitability and appropriateness of, and investment strategies for, Digital Assets. You acknowledge and agree that you shall access and use the WITHBIT Platform at your own risk. Seek advice from an independent financial adviser and/or legal adviser if you have any concerns

1-4. The information and Services provided on the WITHBIT Platform are not provided to, and may not be used by, any individual, corporate or institution in any jurisdiction where the provision or use thereof would be contrary to applicable laws, rules or regulations of any Regulatory Body or where WITHBIT is not authorized to provide such information or Services. It is the User's responsibility to ensure he/she is compliant with applicable laws, rules or regulations and WITHBIT (and the INBLOCK Ltd.) cannot be held responsible for any failure on the part of the User.

1-5. WITHBIT reserves the right to change the Terms at any time. Any material changes to these Terms will be notified to the Users.

1-6. You agree to pay all fees associated with or incurred by you, by your User Account, the Orders you enter into, and the Services you receive (please see section 14 of these Terms).

1-7. By using the WITHBIT Platform you acknowledge and agree that (a) WITHBIT (and the INBLOCK Ltd.) is not acting as your broker, intermediary, agent or adviser or in any fiduciary capacity and (ii) no communication or information provided to you by WITHBIT (or the INBLOCK Ltd.) shall be considered on construed as advice.

2. INTERPRETATION

2-1. Unless otherwise defined herein or the context otherwise requires, defined terms used in these Terms, shall have the following means:

2-1-1. Airdrop: the allocation of a certain amount of the same or newly created Digital Asset(s) to the holders of existing Digital Assets.

2-1-4. Digital Assets: means BTC, ETH, and other distributed ledger technology, or mathematically based or cryptographic protocols that are network-based and are a medium of exchange that (i) may be centralized or decentralized (but not issued by a sovereign or government entity), (ii) allow for borderless transfer-of-ownership, and (iii) may be used to buy goods and services.

2-1-5. Business Day: a day (other than a Saturday or Sunday or public holiday in Hong Kong and any day on which a tropical cyclone warning no.8 or above or a "black" rain warning signal is hoisted in Hong Kong at any time between 9.00am and 5.00pm) on which banks are open in Hong Kong for general commercial business.

2-1-6. Exchange Ledger: has the meaning set out in as defined in section 10.1

2-1-7. Fee Schedule: WITHBIT's current fee schedule, which can be found here.

2-1-11. WITHBIT IP: all Intellectual Property owned, used, or held for use, by WITHBIT in, or in connection with the Services, the WITHBIT Platform and its business.

2-1-12. WITHBIT Platform: the platform hosted by INBLOCK Ltd. for the provision of the Services located at https://withbit.com/.

2-1-13. WITHBIT Representative(s): WITHBIT's directors, officers, managers, employees, consultants and agents from to time to time.

2-1-14. Holding Companies: a holding company as defined in Section 2 of the Companies Ordinance (Chapter 32, Laws of Hong Kong), save that any reference to a body corporate in such section 2 shall be deemed to include a reference to body corporates incorporated or established outside of Hong Kong, or under any other statutory provision.

2-1-15. Hong Kong: the Hong Kong Special Administrative Region of the People's Republic of China.

2-1-16. Intellectual Property: patents, trademarks, designs rights, trade and business names, internet domain names, logos, copyrights (including rights in computer software), goodwill, the right to use and protect confidential information and know-how, database rights, and other intellectual property rights in each case whether registered or unregistered (including all rights to apply for and be granted renewals, extensions and rights to claim priority from, such rights and any similar forms of protection) in force anywhere in the world.

2-1-17. Limit Order(s): has the meaning set out in as defined in section 10.2.1.

2-1-19. Order(s): any order made by a User through the WITHBIT Platform pursuant to the Services.

2-1-20. Order Receipt(s): a receipt sent by WITHBIT to the User relating to an Order.

2-1-21. OTC Trade: has the meaning set out in as defined in section 11.1.

2-1-22. Pre-sale(s): a method that distributes pre-sale token(s) in respect of a particular project in exchange for a contribution from a User.

2-1-23. Pre-Sale Terms of Use: WITHBIT's Token Pre-sale Terms of Use. The Token Pre-sale Terms of Use are expressly incorporated into these Terms.

2-1-24. Privacy Policy: WITHBIT's Privacy Policy, which can be found here .

2-1-25. Regulatory Body: any relevant government, quasi-government, agency, tax authority or other regulatory body and/or law enforcement agency (excluding, for the avoidance of doubt, the rules of any securities exchange).

2-1-26. Service or Services: the provision of an online Digital Asset trading platform and exchange through the WITHBIT Platform provided by and proprietary to INBLOCK Ltd.

2-1-27. Subsidiaries: a subsidiary as defined in Section 2 of the Companies Ordinance (Chapter 32, Laws of Hong Kong), save that any reference to a body corporate in such section 2 shall be deemed to include a reference to body corporates incorporated or established outside of Hong Kong, or under any other statutory provision.

2-1-28. System Failure: a failure of any computer hardware or software used by WITHBIT or any telecommunications lines or devices used by WITHBIT

2-1-29. Transfer Costs Schedule: WITHBIT’s current transfer cost schedule, which can be found here.

2-1-30. User or Users: a "Not Verified (Tier 0) User", "Verified (Tier 1) User", a "Certified (Tier 2) User" or a "Corporate User" (please see the verification schedule for further details of the different types of user and the associated know-your-client requirements).

2-1-31. User Account: the verified and registered account of a User.

2-1-32. User Bank Account: has the meaning set out in as defined in section 15.1.1.

2-1-33. User Statement: has the meaning set out in as defined in section 16.1.

2-2. Working Hours: 9.30am to 5.30pm on a Business Day in the place of receipt of a notice.

2-3. "We, us and our" refers to WITHBIT; "you and your" refers to you as the User.

2-4. Any words following the terms including, include, in particular, for example or any similar expression shall be construed as illustrative and shall not limit the sense of the words, description, definition, phrase or term preceding those terms.

3. GENERAL TERMS OF SERVICE

3-1. In order to use the WITHBIT Platform you must first become a User by successfully providing the required identification information pursuant to our AML Policy. The AML Policy is expressly incorporated into these Terms. These standards are designed to prevent the use of the WITHBIT Platform to aid money laundering or terrorist financing activities. We take compliance very seriously and it is our policy to take all necessary steps to prohibit fraudulent transactions, report suspicious activities, and actively engage in the prevention of money laundering and related acts that facilitates money laundering, terrorist financing or any other financial crimes.

3-2. By visiting, accessing or using the WITHBIT Platform, you confirm, represent and warrant to WITHBIT that:

3-2-1. you (as the User) are at least 18 years old;

3-2-2. you have the legal capacity to accept these Terms and to agree to be bound by the Terms in their entirety;

3-2-3. you have provided WITHBIT with accurate, true and complete information about yourself as a "User";

3-2-4. all funds exchanged or to be exchanged by you in the future using the WITHBIT Platform are not and will not be the direct or indirect proceeds of any criminal or fraudulent activity;

3-2-5. you are not located in, or resident of, any jurisdiction where the provision or use of the WITHBIT Platform would be contrary to applicable laws, rules or regulations of any governmental authority or regulatory organization or where WITHBIT is not authorized to provide such a platform and/or the Services;

3-2-6. you have not previously been suspended or removed from using the WITHBIT Platform;

3-2-7. you have read, understood and agree to our AML Policy, Privacy Policy, Fee Schedule and Transfer Costs Schedule (all of which are expressly incorporated into these Terms).

3-2-8. you (as the User) are at least 18 years old;

3-3. WITHBIT reserves the right to change these Terms at any time. Any material changes to these Terms will be notified to the Users.

3-4. WITHBIT does not provide or issue to its Users any Digital Assets. All Digital Assets exchanged or traded by and between the Users originate from the Users themselves.

3-5. By using the WITHBIT Platform you acknowledge and agree that (a) WITHBIT(and the INBLOCK Ltd.) is not acting as your broker, intermediary, agent or adviser or in any fiduciary capacity and (ii) no communication or information provided to you by WITHBIT (or the INBLOCK Ltd.) shall be considered on construed as advice.

4. RISK DISCLOSURE

4-1. Trading Digital Assets carries a high level of risk, and may not be suitable for you. You should be aware that you may sustain a total loss of the funds in your User Account. When accessing or using the WITHBIT Platform, you should consider all risks in relation to the trading of Digital Assets including the following risks (on a non-exhaustive basis):

4-1-1. the risk of loss in trading Digital Assets may be substantial and losses may occur over a short period of time;

4-1-2. the price and liquidity of Digital Assets has been subject to large fluctuations in the past and may be subject to large fluctuations in the future;

4-1-3. legislative and regulatory changes or actions in your local jurisdiction or at the international level may adversely affect the use, transfer, exchange and value of Digital Assets;

4-1-4. In your jurisdiction, WITHBIT may not be regulated as a financial institution, deposits in your Digital Asset Account and your Fiat Account may not be considered deposits under the laws, rules or regulations applicable in Hong Kong or your jurisdiction. As at the date of these Terms the Digital Assets market is largely unregulated with no (or little) participant protection; however this market is likely to be subject to increasing regulation in the future and Users should understand the risks associated with this;

4-1-5. Digital Assets are not legal tender, are not backed by any government, and Digital Asset Account(s) and value balances are not subject to deposit insurance and investor protections;

4-1-6. Transactions in Digital Assets may be irreversible, and, accordingly, losses due to fraudulent or accidental transactions may not be recoverable and some Digital Asset transactions shall be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that you initiate the transaction;

4-1-7. the value of Digital Assets may be derived from the continued willingness of market participants to exchange Fiat Currency for Digital Assets, which may result in the potential for permanent and total loss of value of a particular Digital Asset should the market for that Digital Asset disappear;

4-1-8. the nature of Digital Assets may lead to an increased risk of fraud or cyber-attack, and may mean that technological difficulties experienced by WITHBIT may prevent the access to or use of your Digital Assets;

4-1-9. any bond or trust account maintained by WITHBIT for the benefit of its Users may not be sufficient to cover all losses due to theft or fraud incurred by Users;

4-1-10. the placing of certain Orders (e.g. "stop loss" or "stop limits" orders) that are intended to limit losses to certain amounts may not always be effected because market conditions or technological limitations may make it impossible to execute such orders;

4-1-11. the prices quoted on the WITHBIT Platform may not necessarily reflect the broader market;

4-1-12. the use of electronic trading systems and communication networks to facilitate trades exposes you to risks associated with the system including the failure of hardware and software system or network down timed access or connection failures. You acknowledge and confirm that WITHBIT (and the INBLOCK Ltd.) will not be responsible for any services disruptions, errors or delays that you may experience while using its Services.

4-1-13. if you are located in Hong Kong, please take note of the Hong Kong Government risk warning on virtual commodities.

4-2. You acknowledge and agree to access and use the WITHBIT Platform at your own risk. The points noted above apply to all trading available on the WITHBIT Platform. However, this brief statement does not disclose all of the risks associated with trading Digital Assets. You should, therefore, carefully consider whether such trading is suitable for you in light of your circumstances and financial resources. Please carefully consider your investment objectives, level of experience, and risk appetite before using any of our Services. Seek advice from an independent financial advisor if you have any doubts.

5. PRE-SALE TOKENS

5-1. At its sole discretion, WITHBIT may allow a Verified (Tier 1) User to participate in a Pre-Sale through the WITHBIT Platform. Please see our Pre-Sale Terms of Use.

6. USERS

6-1. Only Users can buy and sell Digital Assets in exchange for Fiat Currency or other Digital Assets on the WITHBIT Platform. You must not provide access to your User Account to any other party unless expressly agreed to in writing by a WITHBIT Representative. Such consent, if forthcoming, shall be subject to any conditions (including compliance with the AML Policy) as decided by WITHBIT from time to time.

6-2. You hereby authorize WITHBIT and, directly or through its third party service providers, to take any measures that it considers necessary to verify your identity, confirm the information you submit about your linked bank account, and to take any action WITHBIT (or the INBLOCK Ltd.) deem necessary based on the results.

7. REGULATORY COMPLIANCE AND VERIFICATION

7-1. Compliance

7-1-1. In the event that your User Account (or any other account register to or associated with you or your User Account) is suspected of being in breach of any of the provisions of the AML Policy (or any requirements of law or regulation in Hong Kong or another jurisdiction), you agree that we have the right to suspend your User Account and your access to the WITHBIT Platform until a thorough investigation in partnership with any relevant Regulatory Body has taken place.

7-1-2. Should your User Account (or any other account registered to or associated with you or your User Account) be proven to be in breach of any such provisions (or any requirements of law or regulation in Hong Kong or another jurisdiction), you agree that we have the right to close your User Account, restrict your access to the WITHBIT Platform and you agree to forfeit any and all funds in your Fiat Account and/or Digital Asset Account associated with your User Account (or any other account registered to or associated with you or your User Account) to the appropriate authorities.

7-2. Verification

7-2-1. In furtherance of our AML Policy, we reserve the right to require Users to provide additional information to WITHBIT or undergo a background check prior to being authorized as a User or at any point thereafter in accordance with applicable laws. For more detailed information, with regards to our verification tiers, please consult the Verification Schedule found here.

7-3. Applicable rules and regulations for transactions

7-3-1. All of your Orders or requests that are facilitated by INBLOCK through the WITHBIT Platform shall be subject to all laws, regulations, and rules of any applicable Regulatory Body, including but not limited to, money service operator business regulations under the Money Services Operators Ordinance, the relevant regulations of the Hong Kong Customs and Excise Department and the AML Policy.

7-3-2. The Services are at all times subject to all legislative and regulatory changes or actions within Hong Kong or in any other jurisdiction. Any change or action may adversely affect the use, transfer, exchange, and value of your Digital Assets and may result in WITHBIT having to suspend any or all Services at any time. WITHBIT (and the INBLOCK Ltd.) shall not be liable for any such change or action at any time.

8. SECURITY AND ACCESS

8-1. Once we approve your User Account, you will be provided online access to the WITHBIT Platform based on your User Account login credentials and required additional layers of authentication.

8-2. WITHBIT requires the use of multi-factor authentication to keep you and your accounts safe and secure. As a result, you should always use at least two forms of authentication when accessing your User Account and performing certain account operations. Forms of multi-factor authentication in addition to your login credentials may include a specified and supported two-factor authentication (2FA) application.

8-3. If you choose to install and use a 2FA application on any device (e.g. without limitation mobile telephone, smart phone or tablet; including, but not limited to, a device whose operating system has been tampered with), you do so at your own risk. We reserve the right in our sole discretion to prohibit access from or by any device. We may provide your 2FA data to a third party service provider in order to help us authenticate you in accordance with our Privacy Policy.

8-4. Your User Account login credentials and forms of multi-factor authentication, where applicable, have been chosen by you and allow you to access the WITHBIT Platform and the Services we provide. You agree to be solely responsible for maintaining the security of your User Account login credentials and forms of multi-factor authentication. WITHBIT (and the INBLOCK Ltd.) is not responsible or liable for any unauthorized use of your User Account or any other accounts associated with you.

9. COMMUNICATION

9-1. You agree and consent that we may communicate with you in any way, including by way of electronic communication (including, but not limited to, through the WITHBIT Platform and/or email). We consider the email address that you have provided to be your primary means for electronic communication and we will use this email address to provide you with account-related notices and Order Receipts. We may also use this email address for other communications, including notices regarding these Terms, your User Account and any other associated account.

9-2. For security purposes, should a User wish to change his/her email address, he/she must make such request by email to cs@withbit.com and schedule a video conference with a WITHBIT Representative.

9-3. Delivery of any notice to the email address on record with your User Account or any associated User Account will be considered valid notice. If any email is returned as undeliverable, we retain the right to block access to your User Account or any associated User Account until you provide and confirm a new email address.

10. EXCHANGE OPERATIONS AND ORDERS PROCESS

10-1. Exchange Ledger

10-1-1. WITHBIT maintains a private exchange ledger (the Exchange Ledger) to track a User's ownership of (i) Fiat Currency reflected in the User's Fiat Account and (ii) Digital Assets reflected in the User's Digital Asset Account. The account amounts listed in the Exchange Ledger may correspond to funds stored in one or more pooled Digital Asset accounts or one or more omnibus fiat accounts. The Exchange Ledger enables immediate settlement of sale or purchase transactions when the transacting accounts contain sufficient funds. Accordingly, entries in the Exchange Ledger are not publicly disclosed nor broadcast to a given blockchain. Only transfers of Digital Assets from your private account into your Digital Asset Account, or withdrawals of Digital Assets from your Digital Asset Account to your private account, will be confirmed and visible on a given blockchain.

10-2. Orders and settlement

10-2-1. WITHBIT allows Users to set limit orders to buy or sell Digital Assets at a given price, a record of which is maintained in WITHBIT's order book (the Limit Order). When WITHBIT's trading engine matches buy and sell offers in its order book, WITHBIT records the trade on the Exchange Ledger, effectively transferring ownership of the seller's traded Digital Assets to the buyer.

10-2-2. A User may place Market Order(s). A Market Order is a buy or sell Order to be executed immediately at the then 'current market' price. As long as there are willing sellers and buyers, Market Orders are filled. The price of the Market Order is defined by the market as an estimation of the current order book. WITHBIT (and the INBLOCK Ltd.) does not guarantee the price for a Market Order as the price is dependent on market forces.

10-2-3. All buy transactions are purchases of Digital Assets with Fiat Currency or another Digital Asset that settle immediately from a User's pre-funded Fiat Account/Digital Asset Account and are recorded on the Exchange Ledger. All sell transactions are sales of Digital Assets for Fiat Currency or other Digital Asset that settle immediately from a pre-funded Digital Asset Account and are recorded on the Exchange Ledger.

10-2-4. Sell Limit Orders – When a User enters a Limit Order to sell Digital Assets, the full amount of the Digital Assets offered for sale will be placed on hold in the User's Account and any associated fees in Fiat Currency will be deducted by WITHBIT from the sale proceeds. Until the sell Order fills, expires or is cancelled, the amount of Digital Assets being offered for sale will not be available to be used for any other purpose, including other sell Orders or withdrawals. For partially filled sell Orders, the unfilled portion of Digital Assets offered for sale (and to cover any associated fees) will remain on hold until the remaining sell Order is filled, expires or is cancelled.

10-2-5. Buy Limit Order – When a User enters a Limit Order to buy Digital Assets, the full amount of the purchase price and any associated fees in Fiat Currency or other Digital Assets will be placed on hold in the User's Account. Until the buy Order fills, expires or is cancelled, the full amount of Fiat Currency required to fulfil the buy Order will not be available to be used for any other purpose, including other buy Orders or withdrawals. For partially filled buy Orders, the value of the unfilled portion of Fiat Currency required for purchase (and to cover any associated fees) will remain on hold until the remaining buy Order is filled, expires or is cancelled.

10-2-6. If you submit a Buy Limit Order or Sell Limit Order and you have the Digital Assets and/or Fiat Currency available in your User Account, you confirm and agree that you may not be able to cancel this Order prior to it filling (in whole or in part) and that WITHBIT (and the INBLOCK Ltd.) will not be liable to you for the completion of a buy or sell Order after you have submitted a cancelation request.

10-2-7. Any Limit Order or Market Order that exceeds the amount of available purchase price and any associated fees in Fiat Currency and/or Digital Assets in the User's Account will be rejected.

10-2-8. All instructions will be executed on the basis that an actual purchase or sale is intended. Unless otherwise as provided in these Terms, you must have Digital Assets and/or Fiat Currency to cover all sales and/or to pay in full for all purchases in accordance with these Terms. You will fully indemnify WITHBIT on demand against all Loss and liability which it or they may incur as a result of your failure to have Digital Assets and/or Fiat Currency within your User Account.

10-2-9. It is your sole responsibility to review your Order history and Order Receipts on a regular basis in order to meet the period set forth above.

10-3. Exchange operations

10-3-1. Orders you place during regular operation will normally be executed if the market price is at a point within the limits of your Order. However, WITHBIT does not guarantee that your Order will be filled even if the market price was within your limit at the time such Order was placed or was otherwise open. WITHBIT reserves the right to reject or cancel Orders made and/or pending during downtime.

10-3-2. Orders may be subject to delays, difficulties, and/or conditions affecting transmission or execution of Orders over which WITHBIT has no control, including, but not limited to, mechanical or electronic failure or market congestion. WITHBIT (and the INBLOCK Ltd.) shall not be liable (and no refund shall be due) for any delays, difficulties or conditions adversely affecting transmission or execution of Orders.

10-3-3. We reserve the right to require all Orders to pass automated compliance checks. If your Order is flagged for review by any of these checks or if it meets certain defined criteria, it may require our manual review and approval which may delay the fulfilment of the Order. WITHBIT (and the INBLOCK Ltd.) shall not be liable for any such delay.

10-3-4. We may require you to confirm your Order request via telephone or by other forms of authentication prior to execution it if it is deemed suspicious.

10-4. Instructions and dealing practices

10-4-1. You may give instructions verbally, through the Internet, by electronic communication or in such other manner as WITHBIT may permit.

10-4-2. WITHBIT may accept and act upon instructions which it reasonably believes emanated from you. WITHBIT is under no duty to verify your identity or authority, or the geniuses of any signature contained in an instruction. Such instructions will be binding on you and WITHBIT (or the INBLOCK Ltd.) shall incur no liability for accepting or acting upon such instructions, whether or not in fact given by you.

10-4-3. WITHBIT may in its absolute discretion refuse to act on any of your instructions without giving any reason (including, without limitation, if we are in any doubt, at our absolute discretion, as to whether such instructions have been properly authorized, accurately transmitted or received or properly understood by WITHBIT, or if such instructions are illegible or ambiguous). WITHBIT (and the INBLOCK Ltd.) shall incur no liability for so refusing to act.

10-4-4. WITHBIT may perform its duties under these Terms through any member of the INBLOCK Ltd. and/or third parties, who may be acting as agent or as principal. Neither WITHBIT, the INBLOCK Ltd. nor such third party is obliged to account to you for any commissions, fees, spreads (including mark ups or mark downs) or other obtained in connection therewith. In particular, WITHBIT may execute your instructions through such exchanges or dealers as WITHBIT may in its sole discretion decide.

10-4-5. Subject to applicable laws, rules and regulations, WITHBIT may reasonably determine the priority of execution of your instructions, and you have no claim of priority to any other client of WITHBIT.

11. OVER-THE-COUNTER TRADING

11-1. WITHBIT may (in its sole discretion) offer individual Users the opportunity to trade directly with one of WITHBIT's financial partners (an OTC Trade) rather than through the general User trading platform and exchange on the WITHBIT Platform.

11-2. WITHBIT will inform such Users as to the process, manner and any conditions of any such OTC Trade at the time of the requested trade. The completion of any sell or buy Order(s) relating to an OTC Trade shall be via the User's Fiat Account and/or Digital Asset Account, as applicable.

11-3. All OTC Trades shall be subject to these Terms including, but not limited to, all of the disclaimers and limitations of liability contained herein.

12. BLOCKCHAIN NETWORK

12-1. WITHBIT does not own any underlying open source blockchain software and/or network. By using the WITHBIT Platform, you acknowledge and agree that:

12-2. WITHBIT (and the INBLOCK Ltd.) is not responsible for the operation of any underlying blockchain software and/or network(s) that support the Digital Assets, and that WITHBIT makes no guarantee of the functionality, security or availability of such software and networks;

12-3. WITHBIT does not have any ability to prevent or mitigate cyber-attacks and modifications on any blockchain software and/or networks (and that WITHBIT(and the WITHBIT Ltd.) reserves the right in its sole discretion to take all commercially reasonable actions in such an event);

12-4. the underlying protocols may be subject to sudden changes in operation rules (commonly known as "Forks"), and that such changes may materially affect the value, function and/or availability of the Digital Asset held in your User Account; and

12-5. you should not expect any new or additional Digital Assets created by Forks to be credited or accrued to your User Account.

13. AIRDROPS

13-1. By transferring Digital Assets into your User Account, or acknowledge and agree that you will not receive any tokens and/or Airdrops which may ordinarily accrue to you had you kept the relevant Digital Assets within your own private wallet. By using the Service you confirm that WITHBIT may, at its sole discretion, receive and/or accrue any such tokens and/or Airdrops on its own account and that you have no right to claim or request that (i) any token and/or Airdrop is transferred to your User Account or private wallet or (ii) any compensation is paid to you in lieu of not receiving additional tokens and/or Airdrops.

14. FEES

14-1. Trading Fee Schedule

14-1-1. The Fee Schedule is incorporated into these Terms and your acceptance of these Terms and use of the Services is considered to be your acceptance of such Fee Schedule.

14-1-2. We reserve the right to change, modify or increase our Fee Schedule at any time. Any change to the Fee Schedule, including adjustments to any of the tiers or rates, will be posted no fewer than three calendar days before changes are to take effect and no changes will be in effect for fewer than 30 calendar days.

14-1-3. Your use of the Services and/or the WITHBIT Platform following any update to our Fee Schedule is considered to be your acceptance of any such changes.

14-2. Maker/Taker Fee System

14-2-1. The Fee Schedule incorporates a monthly adjusted fee structure that reflects the volume of trades made within a monthly period. Monthly volume is calculated over a rolling period of 31 days. The breakdown of such can be found within the Fee Schedule and is subject to change without notice.

14-3. Transfer Costs Schedule

14-3-1. The Transfer Costs Schedule is incorporated into these Terms and your acceptance of these Terms and use of the Services is considered to be your acceptance of such Transfer Costs Schedule.

14-3-2. We reserve the right to change, modify or increase our Transfer Costs Schedule at any time. Any change to the Transfer Costs Schedule will be posted no fewer than three (3) calendar days before changes are to take effect and no changes will be in effect for fewer than 30 calendar days.

14-3-3. Your use of the Services and/or the WITHBIT Platform following any update to our Transfer Costs Schedule is considered to be your acceptance of any such changes.

14-4. You agree to promptly pay all fees associated with or incurred by your User Account, the Orders you enter into, and the Services you receive.

15. FUNDS AND TRANSFERS

15-1. Funding and withdrawals

15-1-1. We will not accept Fiat Currency on your behalf from a third party. All Fiat Currency received via bank wire transfer to a Fiat Account will only be accepted from a bank account that has been approved by our AML Policy (each, a User Bank Account). Your daily transfer limit will be determined by the levels of verification the WITHBIT compliance team has approved.

15-1-2. All Fiat Currency withdrawals via bank wire transfer from a Fiat Account can only be transferred to a User Bank Account. The initiation of a withdrawal via bank wire or transfer from a Fiat Account using valid User Account login credentials and required forms of multi-factor authentication will be deemed to be an authorization for WITHBIT to complete any such withdrawal to a User Bank Account.

15-2. Source of funds

15-2-1. You agree, represent and warrant that no funds presently in your Fiat Account or Digital Asset Account that you own and/or are a designated representative of, or funds exchanged or to be exchanged by you in the future using the WITHBIT Platform are the direct or indirect proceeds of any criminal or fraudulent activity.

16. ACCOUNT SERVICES

16-1. We provide account statements (each, a User Statement) in addition to Order Receipts to our Users via the WITHBIT Platform and/or email. We intend for the information contained in User Statements and Order Receipts to be accurate and reliable, however, errors may sometimes occur. WITHBIT (and the INBLOCK Ltd.) disclaims any warranty of any kind, whether express or implied, as to any matter whatsoever relating to such information.

16-2. Any Order that has been executed shall be bound to the actual means and results of its execution regardless of any discrepancies between the execution and the reporting for that Order that may occur. We retain the right to enter pricing, Order, and reconciliation adjustments to your Fiat Account and/or Digital Asset Accounts as necessary and appropriate.

16-3. Every transaction indicated or referred to in any User Statement, Order Receipt, or other communication shall be deemed and treated as authorized and correct as ratified and confirmed by you unless we receive written notice to the contrary within three Business Days from the completion of the transaction.

16-4. It is important for you to understand that it is your sole responsibility to access your User Account and review Order Receipts on a regular basis, and that you will be deemed to have accessed your User Account and reviewed this information on at least a monthly basis. If for any reason you are unable to do so, or do not have account notifications turned on or deliverable, it is your responsibility to notify us immediately at cs@withbit.com.

17. ACCURACY OF INFORMATION

17-1. While we strive to provide you with accurate information, we cannot guarantee that information on the WITHBIT Platform will always be accurate. As a result, WITHBIT (and the INBLOCK Ltd.) are not liable to you, any other person or any institution:

17-1-1. for the accuracy, completeness, timeliness or correct order of information;

17-1-2. for any changes or updates to these Terms, including without limitation, to our fees, with or without notice;

17-1-3. for any decision you make or action you take by relying on any of the information on the WITHBIT Platform;

17-1-4. for any transaction you initiate or attempt that is not completed;

17-1-5. for any transaction that is completed;

17-1-6. for the price at which you buy or sell Digital Assets on the WITHBIT Platform;

17-1-7. if you are not able to buy or sell Digital Assets on the WITHBIT Platform; and

17-1-8. for any law, rule, regulation, action, enforcement or order in your jurisdiction that makes the use, ownership, purchase or sale of Digital Assets illegal or impermissible.

18. INTELLECTUAL PROPERTY AND RELATED RIGHTS

18-1. Proprietary rights and limitations on use of the WITHBIT Platform

18-1-1. The WITHBIT Platform is our proprietary platform. All rights are reserved. The WITHBIT Platform is protected by copyright and other Intellectual Property laws.

18-1-2. You agree not to modify, copy, reproduce, retransmit, distribute, sell, publish, broadcast, create derivative works from, or store WITHBIT (or any portion thereof, including WITHBIT source code or data or other information provided via the WITHBIT Platform), without the express prior written consent of WITHBIT.

18-1-3. You may only use the WITHBIT Platform for the purpose intended as an online Digital Assets trading platform and exchange and not for any other lawful or unlawful purpose.

18-2. License to use WITHBIT Platform

18-2-1. We hereby grant you a non-assignable and non-exclusive personal, worldwide, royalty-free license to use the WITHBIT Platform and to access data and other informational content through the WITHBIT Platform consistent with the use of the Services. All other uses are prohibited. All rights in and to the WITHBIT Platform, and not granted herein, are reserved.

18-3. WITHBIT IP

18-3-1. WITHBIT IP is proprietary to WITHBIT and is protected by applicable Intellectual Property laws and regulations. Nothing contained in these Terms should be construed as granting any license to or right to use any of the WITHBIT IP without WITHBIT's express written consent. Any unauthorized use of the WITHBIT IP is strictly prohibited and may result in appropriate action being taken by WITHBIT.

18-4. Third party websites

18-4-1. WITHBIT may link to other websites operated by or with content provided by third parties, and such other websites may link to our website. WITHBIT has no control over any such other websites or their contents and will have no liability arising out of or related to such websites or their contents. The existence of any such links does not constitute an endorsement of such websites, the contents of the websites or the operators of the websites. WITHBIT is providing these links to you only as a convenience. WITHBIT may also use third parties to gather User's data from financial institutions.

18-5. Reference to Withbit by media

18-5-1. Journalists and media representatives are encouraged and hereby authorized to refer to WITHBIT provided that the reference is accompanied by: (a) attribution to WITHBIT; and (b) a hyperlink to withbit.com as feasibility permits. For all media related inquiries, please contact cs@withbit.com.

19. SYSTEMS OPERATIONS

19-1. System disruptions or malfunctions

19-1-1. We reserve the right to reverse and/or cancel one or more Orders in the event of (i) any disruption or malfunction in the operation of any electronic communications, trading facilities, storage facilities, recording mechanisms or other components of or integral to the WITHBIT Platform or of the Digital Assets, (ii) any other severe business disruption to the WITHBIT Platform, its systems or the Digital Assets, where the nullification of transactions may be necessary for the maintenance of a fair and orderly market or the protection of you and the public interest.

19-1-2. If such a disruption or malfunction occurs, a WITHBIT Representative may review such Orders and declare such Orders arising out of the operation of WITHBIT during such period null and void.

19-2. Systems not guaranteed

19-2-1. WITHBIT uses commercially reasonable efforts to provide Users with a reliable and secure platform. From time to time, interruptions, errors or other deficiencies in service may occur due to a variety of factors, some of which are outside the control of Withbit. These factors can contribute to delays or errors in service or system outages. Users may experience difficulties in accessing their User Account, in withdrawing their Fiat Currency or Digital Assets, and in placing and/or cancelling Orders.

20. DISCLAIMERS

20-1. The Services that we provide through the WITHBIT Platform are provided to you on a strictly "as is," "where is" and "where available" basis. WITHBIT, the INBLOCK Ltd. and the WITHBIT Representatives do not represent or warrant to the accuracy, completeness, correctness, no infringement, merchantability, or fitness for a particular purpose of the WITHBIT Platform or the information contained therein or services contained thereon.

20-2. In no event will WITHBIT, the INBLOCK Ltd. or the WITHBIT Representatives be liable to you or others for any Loss arising from or out of:

20-2-1. the existence, furnishing, functioning or your use of the WITHBIT Platform and/or the Services;

20-2-2. any act or omission in connection with your accessing the WITHBIT Platform and/or using the Services;

20-2-3. any inaccuracies or incompleteness, delays, interruptions, errors or omissions, including (to the extent permissible by law), but not limited to, those arising from the negligence or recklessness of WITHBIT, the INBLOCK Ltd. and/or the WITHBIT Representatives, or contingencies beyond their control in procuring, compiling, interpreting, computing, reporting, or delivering the WITHBIT Platform, the Services thereon or the information therein;

20-2-4. any failure or delay relating to a funds transfer caused by (or as a result of any action taken or omission of) any bank and/or financial institution;

20-2-5. any transmission of any viruses, spyware, worms, Trojan horses or other malware which may infect a User's equipment,

20-2-6. any System Disruptions or Malfunctions (as set out in section 19) or System Failure, which prevents us from fulfilling our obligations under these Terms (including any failure of mechanical or electronic equipment or communication lines, telephone or other interconnect problems);

20-3. Furthermore, you agree that any act or omission made by WITHBIT or one of our banks in reliance upon or in accordance with any provision of any rule or regulation of Hong Kong, Hong Kong Customs and Excise or any other Regulatory Body having jurisdiction over such party shall constitute ordinary care.

21. LEGAL COSTS

21-1. You agree to indemnify WITHBIT for legal costs and expenses directly related to the structuring, support and/or defense of your User Account or the assets contained therein, and for any Loss related to any regulatory inquiry, legal action, litigation, dispute, or investigation.

21-2. WITHBIT will be entitled to charge your User Account for such costs without notice, including legal and enforcement related costs that we incur. Any withholding by us will last for a period of time that is reasonably necessary to resolve any regulatory or legal issue at hand, and we may place any amounts garnered from you in a separate account, and will pay you the remaining balance after any noted issue has been resolved.

22. RECORDING AND ARCHIVING

22-1. You acknowledge and agree that for our mutual protection we may electronically record any of our telephone conversations and electronic communications with you and archive all online transactions, communications and information relating to your User Account and/or your use of the WITHBIT Platform.

23. ADVICE

23-1. You acknowledge and agree that in providing the Services WITHBIT (and the INBLOCK Ltd.) is NOT and does NOT provide you with legal, tax, investment, financial or other advice, and to the extent you deem necessary, you will consult professionals in your own jurisdiction prior to using the Withbit Platform.

23-2. All investment decisions are made solely by you. Notwithstanding anything in these Terms, we accept no responsibility whatsoever for and shall in no circumstances be liable to you in connection with such decisions. Under no circumstances will the operation of the WITHBIT Platform be deemed to create a relationship that includes the provision or tendering of investment or financial advice.

24. TAX

24-1. You confirm and agree that it is your responsibility to determine what, if any, taxes apply to the Orders and trades you complete using the WITHBIT Platform and it is your responsibility to report and remit the correct tax to the appropriate tax authority. You agree that WITHBIT (and the INBLOCK Ltd.) is not responsible for determining whether taxes apply to your Orders or for gtc-collecting, reporting, withholding or remitting any taxes arising from any Orders.

25. NON SOLICITATION

25-1. All Orders received through the WITHBIT Platform will be considered unsolicited, which means that you have NOT received any investment advice from WITHBIT, the INBLOCK Inc. or the WITHBIT Representatives in connection with any of your Orders, and that we will not conduct a suitability review of any such Orders. You also acknowledge and agree that you have NOT and do not expect to receive any advice (as per section 23) from WITHBIT, the INBLOCK Ltd. or the WITHBIT Representatives in connection with your Orders. In addition, your review of our Blog and/or FAQ does not constitute any solicitation or investment advice.

26. LEGAL PROCESS

26-1. We may comply with any writ of attachment, execution, garnishment, tax levy, restraining order, subpoena, warrant or other legal process, which such party reasonably and in good faith believes to be valid. We may, but are not required to, notify you of such process by telephone, electronically or in writing. You agree to indemnify WITHBIT (and the INBLOCK Ltd.) in respect of any Loss associated with our compliance with any process that WITHBIT (or any member of the INBLOCK Ltd.) believes reasonably and in good faith to be valid.

26-2. If we are not fully reimbursed for our record research, photocopying and handling costs by the party that served the process, we may charge such costs to your User Account, in addition to any legal process fees.

26-3. You further agree that we and our financial institutions may honor legal process that is served personally, by mail, or by facsimile transmission at any of our or their respective offices (including locations other than where the funds, records or property sought is held), even if the law requires personal delivery at the office where your WITHBIT Platform records are maintained.

27. ACCOUNT CLOSURE AND SUSPENSION

27-1. Account closure

27-1-1. You may close your User Account at any time by providing written notice to us at cs@withbit.com. Closing your User Account will not affect any rights and obligations incurred prior to the date of your User Account being closed.

27-1-2. You will be required to either cancel or complete all open Orders and, in accordance with the provisions of these Terms, provide transfer instructions of where to transfer any Fiat Currency and/or Digital Assets remaining in your Fiat Account or Digital Asset Account.

27-1-3. You are responsible for any fees, costs, expenses, charges or obligations (including, but not limited to, attorney and court fees or transfer costs of Fiat Currency or Digital Assets) associated with closing your User Account. In the event that your account closing costs exceed the value in your User Account, you will be responsible for reimbursing WITHBIT.

27-1-4. You may not cancel your User Account and/or your User Account to avoid paying any fees otherwise due or any examination as part of our AML Policy.

27-2. Account suspension, termination and cancellation

27-2-1. We may discontinue, terminate, suspend, or change any aspect of the Withbit Platform and/or the Services, or its availability to you, at any time without notice.

27-2-2. In addition, we reserve the right to suspend, modify, deactivate or terminate your User Account as well as your access to all or any portion of the WITHBIT Platform immediately and without notice if (i) you violate any provision of these Terms; (ii) we in good faith suspect that your account is in breach of our AML Policy; (iii) we are required to do so by a Regulatory Body, court order, facially valid subpoena or binding order of a government authority; (iv) you or your User Account is subject to any pending litigation, investigation or governmental proceeding; or (v) for any other reason that we may reasonably conclude.

27-2-3. If you do not log into your User Account for two years then WITHBIT may close your User Account.

27-2-4. Subject to the provisions of these Terms, you agree that if your User Account is closed for any reason and unless otherwise required by law, court order or subpoena, WITHBIT is authorized to either (i) send any remaining Digital Assets to a Digital Asset address that you provide within 48 hours of receiving notice of your User Account being closed or (ii) sell any remaining Digital Assets on the open market and credit the proceeds in the Fiat Account associated with your User Account. The total amount of Fiat Currency in your Fiat Account, less any applicable fees, will be distributed to you via bank wire transfer to the User Bank Account on record.

27-3. Unclaimed funds

27-3-1. In the event that your User Account is closed for any reason, WITHBIT may be required to report any remaining funds in your Fiat Account or any remaining Digital Assets in your Digital Asset Account, as unclaimed property.

27-3-2. If this occurs, WITHBIT will use reasonable efforts to notify you at the email address shown in WITHBIT's records. If you fail to respond to any such notice within forty-eight hours, or as otherwise required by law, WITHBIT may be required to deliver any such funds to the Hong Kong authorities as unclaimed property. WITHBIT reserves the right to deduct an administrative fee resulting from such unclaimed funds, as permitted by applicable law.

28. MISCELLANEOUS TERMS

28-1. Additional terms

28-1-1. If any provision in these Terms is invalid or unenforceable under applicable law, the remaining provisions will continue in full force and effect.

28-1-2. These Terms (including any other terms and/or documents incorporated herein by reference) constitutes the entire agreement between you and WITHBIT relating to your use of or participation in the WITHBIT Platform and these Terms supersede any and all other agreements, oral or in writing, with respect thereto between you and WITHBIT.

28-1-3. The failure of any WITHBIT to insist upon strict compliance with any term or provision shall not be construed as a waiver with regard to any subsequent failure to comply with such term or provision.

28-1-4. These Terms shall not be construed to waive rights that cannot be waived under applicable national, state and federal laws.

28-1-5. These Terms, or your rights and obligations hereunder, may not be transferred or assigned by you. However, WITHBIT shall be entitled to freely assign its rights and the benefit of these Terms as it see fits. Any attempted transfer or assignment by you in violation hereof shall be null and void. These Terms shall be binding and inure to the benefit of the parties hereto, our successors and permitted assigns.

28-1-6. In the event that WITHBIT is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have gtc-collected from you as part of such merger, acquisition, sale or other change of control.

28-1-7. The provisions of these Terms shall survive the termination or expiration of these Terms.

28-1-8. Nothing in these Terms shall be deemed to constitute, create, imply, give effect to, or otherwise recognize a partnership, employment, joint venture, or formal business entity of any kind; and the rights and obligations of the parties shall be limited to those expressly set forth herein.

28-1-9. Except for the indemnity and exculpation provisions herein, nothing expressed in, mentioned in, or implied from these Terms is intended or shall be construed to give any person other than the parties hereto any legal or equitable right, remedy, or claim under or in respect to these Terms to enforce any of its terms which might otherwise be interpreted to confer such rights to such persons, and these Terms and all representations, warranties, covenants, conditions and provisions hereof are intended to be and are for the exclusive benefit of you and WITHBIT.

28-2. Notice

28-2-1. Any notice to be sent to WITHBIT in connection with these Terms shall be in writing in English and delivered by hand, email, registered post or courier using an internationally recognized courier company. A notice shall be effective upon receipt and shall be deemed to have been received: (i) at the time of delivery, if delivered by hand, registered post or courier; or (ii) at the time of transmission if delivered by email provided that in either case, where delivery occurs outside Working Hours, notice shall be deemed to have been received at the start of Working Hours on the next following Business Day.

28-2-2. The addresses and email addresses of INBLOCK Ltd. for the purpose of section 28.2.1 are:

28-3-1. You agree that your obligations and the obligations of each User set forth in these Terms are necessary and reasonable in order to protect WITHBIT and its business. You expressly agree that due to the unique nature of our business, monetary damages would be inadequate to compensate us for any breach by you of your covenants and agreements set forth in these Terms. Accordingly, you acknowledge and agree that any such violation or threatened violation shall cause irreparable injury to WITHBIT and that, in addition to any other remedies that may be available, in law, in equity or otherwise, INBLOCK shall be entitled to obtain injunctive relief against the threatened breach of these Terms or your continuation of any such breach, without the necessity of proving actual damages.

28-3-2. These Terms, your use of the WITHBIT Platform and the Services, your rights and obligations, and all actions contemplated by, arising out of or related to these Terms shall be governed by the laws of Hong Kong, as if these Terms are a contract wholly entered into and wholly performed within Hong Kong.

28-3-3. Any controversy, claim or dispute arising out of or relating to these Terms or the breach thereof shall be settled solely and exclusively by binding arbitration held in the Hong Kong International Arbitration Centre (HKIAC), administered by HKIAC and conducted in English. You expressly agree that any dispute about the scope of these Terms shall be resolved in arbitration in accordance with this section. In the event that you threaten to litigate a dispute in court, we may institute arbitration to enjoin you from filing a complaint or petition in court; provided, however, that INBLOCK may, without inconsistency with this arbitration provision, apply to any court for a preliminary remedy (i.e. equitable or injunctive relief, or to seek enforcement of the arbitral award). You expressly agree that an arbitrator may issue all appropriate declaratory and injunctive relief necessary to ensure the arbitration of disputes. Any such arbitration shall be conducted in accordance with the then prevailing HKIAC Arbitration Rules & Procedures.

28-3-4. You agree that all Orders, trades, transfers, withdrawals or sales on WITHBIT and contemplated according to these Terms shall be deemed to have occurred in Hong Kong and be subject to the internal laws of Hong Kong without regard to its conflicts of laws provisions.

28-3-5. Section headings in these Terms are for convenience only, and do not govern the meaning or interpretation of any provision of these Terms.

28-4. Questions and contacts

28-4-1. If you have any questions or would like more information about WITHBIT, please feel free to contact us at cs@withbit.com. If you need help or would like to contact us with a complaint, please contact our Support team using one of the following methods:

(a) Email cs@withbit.com using the email address associated with your User Account; or

We collect, use and disclose personal data for business purposes only and to meet the needs of our Users, including:

• providing the services you request

• day-to-day operation and maintenance of accounts

• managing our global websites and services

• understanding our customers and their needs

• designing and improving our services

• to comply with our regulatory, legal and ethical obligations or the request of any Regulatory Body (including warrants, subpoenas, court orders, or with a regulator or law enforcement agency request, and in connection with criminal investigations or to meet government tax reporting requirements)

• contacting you or responding to your inquiries and comments

• investigating any suspicious activities

• protecting our rights and property

• for direct marketing purposes

We may from time to time collect personal data from visitors to our websites and individuals who participate in a promotion, contest or survey.

If you decide to withhold certain information, it may limit our ability to provide you with the Services and/or your ability to use the WITHBIT Platform.

Disclosure of personal data

We do not disclosure your personal data to other parties other than to members of the WITHBIT(INBLOCK Ltd.) and trusted third parties(including financial partners and banking institutions) who assist us in our provision of the Services to Users (including to parties that provide administrative, telecommunications, computer, trade execution, payment or clearing, prepare and mail account statements, transaction confirmations and other services in connection with the Services) on the basis that those parties agree to keep your information confidential. We may also release your personal data to non-affiliated third parties at your direction or for which you have provided your express consent, or if required by law, regulation or any Regulatory Body(such as the Hong Kong Internal Revenue Department, the Hong Kong Customs and Excise Department and other international data protection authorities). We may also share US residents’ personal information with other financial institutions as authorized under Section 314(b) of the US Patriot Act, and with law enforcement or tax authorities, including the US Internal Revenue Service (pursuant to the Foreign Account Tax Compliance Act, "FATCA") and the US FinCEN. FATCA reporting to the IRS may also apply to US nationals residing abroad.

Data storage and protection

The personal information that we collect from you will be stored in Hong Kong and relevant other countries, which may have different privacy laws and standards than those in your country of residence. Your personal information may be transferred to or processed in the Hong Kong by us or a third party service provider working for us, or by one of the members of the WITHBIT(INBLOCK Ltd.). By submitting personal information via our website or other means, you agree to such storage, transfers and processing. We take all appropriate steps to store and protect your personal data. All personal data that is not directly related to our business or upon fulfilment of the purpose for which it was retained will be deleted after a reasonable period of time.

We also conduct regular internal evaluations of our business practices and procedures in order to protect your personal data.

Online security

In addition to our security measures, you can also take steps to maximize your security online and to protect your confidential information. We encourage you to use strong passwords with mix of uppercase, lowercase, numbers and special symbols. Our support teams will never ask you for your personal details such as username or identification number via email and we will never ask for your password (as we do not keep any password in our databases).

Usage of cookies

Cookies are small amounts of data that a website can send to your web browser and store on your computer. We use both HTML cookies and Local Shared Objects (sometimes referred to as Flash cookies) that are built for use with the Adobe® Flash® Player for authentication purposes and to enhance navigation and website functionality optimize their experience.

Your personal information

You are permitted under the Personal Data (Privacy) Ordinance (Cap. 486) to access your personal information we hold about you. You may request such access by completing the Data Access Request Form as specified under section 67 of the Personal Data (Privacy) Ordinance (Cap. 486) and sending an e-mail to cs@withbit.com. There may be circumstances where we are unable to provide access to all of your personal information. We may deny or restrict access for legally permissible reasons, such as situations where the information contains references to other individuals and is not reasonably severable, or where it cannot be disclosed for legal, security, or commercial proprietary reasons. We will advise you of any reason for denying or restricting an access request to the extent permitted by law, rule or regulation.

Changes to our privacy policy

Any changes or updates to this Privacy Policy will be posted on this page.

The WITHBIT AML/CFT Policy is designed to ensure that all Group Companies comply with the requirements and obligations set out in Hong Kong and international legislations, regulations, rules and Industry Guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. The AML Policy sets out the minimum standards which must be complied with by all WITHBIT Companies and employees and includes:

· Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the Group;

· Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

· Procedures for reporting suspicious fraudulent use of identification documents to the relevant law enforcement authorities as appropriate;

· The maintenance of appropriate records for the minimum prescribed periods;

· Training and awareness for all relevant employees;

· And the provision of appropriate management information and reporting to senior management of the Group's compliance with the requirements.

· WITHBIT may require its clients to provide additional information or documentation to fulfil our legal obligations and where it deems appropriate refuse any client or transaction that is suspected of being related to financial crime.

The appointment of a Group Money Laundering Reporting Officer (GMLRO) and Business Unit Money Laundering Reporting Officers (MLROs) of sufficient seniority, who have responsibility for oversight of Group and Business Unit compliance with relevant legislation, regulations, rules and industry guidance;